FCA has fined Ghana International Bank nearly £6m for failings in its financial crime prevention controls in respect of its correspondent banking business. It found that, for a 5 year period to the end of 2016, it did not perform adequate due diligence on banks wanting to set up correspondent banking relationships, with the result that it could not properly assess the ML/TF risks posed by the respondent banking business. It did not properly identify the business nor the payments relating to it, had poor and patchy policies that means employees could not tell how they were supposed to onboard the business, and failed to carry out routine monitoring of customers.
The firm had taken some measures when Ghana had been added to a high risk list, and in reaction to various FCA publications, and had taken advice on its policies but failed to implement recommendations. Eventually, FCA carried out a supervisory visit at the end of 2016 as a result of which the bank voluntarily agreed not to take on new customers, and that restriction is still in place.
FCA says that there was no evidence of actual money laundering, but the risks were significant – and the transactions processed under the correspondent banking relationship were worth £9.5 bn.